For Immediate Release
Tuesday, December 1, 2015
Contact: Camilla Feibelman, Rio Grande Chapter Director, camilla.feibelman@sierraclub.org, 505.715.8388
Resources: Power Point Presentation | Video of Methane Venting in Aztec NM
A coalition of groups from around the state announced Tuesday that more than 25,000 New Mexicans have submitted comments in support of Obama Administration safeguards that would help to reduce dangerous methane leakage from oil and gas operations around the country.
Citizens have until Friday, Dec. 4, to comment and can do so at www.sc.org/CutMethane
“More than 25,000 New Mexicans have joined over 700,000 people throughout the country in support of the President’s efforts to control methane pollution,” said Alex Renirie, an organizer for the Sierra Club. “These rules are part of the President’s commitments in the Paris Climate Negotiations, but they will also help to reduce New Mexico’s methane hotspot that sits over the Four Corners.”
Methane is a highly potent greenhouse gas that leaks or is vented or flared at oil and gas drilling sites and along the chain of production. On a 20-year timescale, methane is 86 times more powerful than carbon dioxide as a climate-warming gas. The EPA Methane Rules will apply to all existing and modified oil and gas operations, while a forthcoming BLM rule will apply to existing, new and modified sources on public lands.
“We are glad to reach this milestone with the EPA methane rule and look forward to a strong complementary BLM rule in order to cover a wider range of methane pollution, including that on public land,” said Tom Singer, a Senior Policy Advisor with the Western Environmental Law Center.
Oil and natural-gas producers in New Mexico emitted more than 250,000 metric tons of methane in 2013 — equivalent to the amount of gas used to heat and power all of Albuquerque (239,000 homes), leading to the largest methane cloud in the country over the Four Corners area. Though methane itself is transparent, the impacts on the environment and for the communities are hard to miss, according to local residents.
Four Corners residents agree:
“Methane pollution is glaringly obvious we must address this problem,” said Farmington-area rancher, farmer and business owner Tweeti Blancett. “We farm on the Animas River, and within a 5-mile radius is one of the biggest sources of this plume. It is not ALL naturally occurring and can be linked to the oil and gas operations in the area and the lack of enforcement by the government entities.”
“We live in the middle of this. It has always been a sacrifice zone to Big Energy with little to no recourse for the health and environment of the people, the land, air and water. We suffer in silence no more” said Victoria Gutierrez, member of the Navajo Nation. “The San Juan Basin and Four Corners Region is surrounded by fracking sites, rampant oil and gas production, and the largest point source of methane and carbon pollution in the entire country.”
The following are groups that participate in the New Mexico Methane Coalition and have worked to collect comments: Sierra Club, Conservation Voters New Mexico Education Fund, 350 NM, NM Interfaith Power & Light, Diné Citizens Against Ruining Our Environment, Santa Fe Green Chamber of Commerce, Western Environmental Law Center, Earthworks, Environmental Defense Fund.
Overview
Overview of Methane Rule and its Importance to New Mexico
Methane is a highly potent greenhouse gas. On a 20-year timescale, it is 86 times[i] more powerful than carbon dioxide.
The oil and gas industry is the largest industrial source of methane pollution. In 2013, this sector emitted over 7.3 million metric tons[ii] of methane. From a standpoint of climate disruption, that’s equivalent to CO2 emissions from more than 160 coal-burning power plants.[iii]
EPA’s proposal represents the first-ever methane rules for the oil and gas industry. The proposed reduction methods are sensible, cost-effective, and already in use in the oil and gas industry. Under the standard, oil and gas operators will install controls that will reduce not only methane, but also smog- and soot-forming pollutants and hazardous emissions.[iv] This will generate significant public health benefits in addition to climate benefits.
However, the rule only covers new and modified infrastructure, even while existing sources are by far the major source of the problem. By 2018, nearly 90% of all methane emissions in the oil and gas sector will come from sources now in existence, which aren’t covered under the proposal.[v]
The U.S. cannot meet its international greenhouse-gas-reduction commitments unless it cuts methane from oil and gas sources by 40-45% from 2012 levels by 2025.[vi] At best, the current proposal will keep methane emissions flat. We cannot achieve the reduction needed unless EPA regulates existing source from the oil and gas sector.
Therefore, while we support EPA’s efforts to develop methane standards for new and modified sources, the agency must begin work on an existing-source rule as it moves forward with the current rule. With optimal methane controls in place, natural gas would still be a dirty and climate-damaging fossil fuel, and fracking would still be dangerous and unnecessary. We support a swift transition to renewable energy and energy efficiency and away from fossil fuels.
New Mexico Specific
Since 2009, New Mexicans have lost an estimated $42.7 million in royalty revenue from increasing leaks, intentional venting, and flaring of natural gas on New Mexico’s public lands. Oil and natural gas producers in New Mexico emitted over 250,000 metric tons of methane in 2013— equivalent to the amount of gas used to heat and power all of Albuquerque (239,000 homes).
Over 180,000 New Mexico residents already suffer from asthma.
Of the over 475 natural gas producers in New Mexico, fewer than 10 have joined EPA’s Natural Gas STAR Program, a voluntary program that encourages companies to stop existing methane leaks and prevent future ones. This demonstrates why voluntary measures are inadequate to address this problem.
Technical Points
We are encouraged that EPA has proposed methane standards for most of the same sources included in the 2012 standard for volatile organic compounds (VOCs). We are also pleased that the agency has extended regulations to downstream sources—that is, those in the transmission and storage segment.
However, the agency has omitted several key pieces of equipment from its regulations:
- Storage vessels, which were covered under the VOC standards but are not included in the methane proposal;
- Liquids unloading operations;
- Pneumatic controllers that operate on an intermittent or snap-acting basis; and
- Compressors at well sites.
These sources are associated with significant methane emissions, and cost-effective controls exist for all of them. EPA must therefore cover them in the final rule. We particularly call attention to storage tanks, which were the only source included in the 2012 VOC rule that was not covered under the methane proposal. This may have been an inadvertent oversight by EPA, and we urge the agency to correct the error by ensuring this source is covered in the final rule.
In many instances, the proposed standard would allow source operators either to capture gas for sale or for a beneficial use on-site, or to direct the captured gas to a completion combustion device such as a flare. From both an environmental and waste avoidance standpoint, the former option is always preferable to the latter. EPA must specify that the use of completion control devices shall be permitted only where it is technically infeasible to capture the gas for sale or on-site use or to use zero-emitting equipment. Such devices must also have a 95.0% combustion efficiency or greater.
We are pleased to see leak detection and repair requirements in the standard for well-sites and compressor stations. However, we believe inspections should be required at least quarterly or monthly (rather than a default semi-annual requirement), and should remain consistent, rather than decreasing upon low leak rate-detection. Under the proposal, the required frequency of inspections for a given operator depends upon the percentage of leaks found in the previous 12-month period. This system will likely incentivize operators to ignore or overlook leaks in order to qualify for a less frequent inspection requirement. EPA should remove this incentive and should require fixed inspections.
The proposal would allow source operators up to six months to repair leaking equipment if it would be unsafe to make the repair within 15 days of discovery. This is an exceptionally long period of time, and the agency should consider shortening it.
EPA should quantify and monetize the public health benefits the methane standard will generate by also reducing emissions of volatile organic compounds, which form smog and soot, and hazardous air pollutants. The agency left these metrics out of its cost-benefit analysis, so the rule’s benefits are understated in its cost-benefit analysis.
EPA also omitted from its cost-benefit analysis monetary savings that would accrue due to sale of conserved gas in the transmission and storage segment. The agency reasons that owners/operators of the infrastructure in that sector do not own the gas that is conserved, and therefore does not enjoy the benefit of the savings. Yet the owner of the gas does realize the benefit of those savings, and a cost-benefit analysis looks at societal costs and benefits—the cost-bearing entity need not be the one to enjoy the benefits for those benefits to factor into the analysis. There is therefore no reason to ignore cost savings from preserved gas in the transmission and storage segment from the analysis.
References
[i] International Panel on Climate Change, Fifth Assessment Report: The Scientific Basis (Sept. 2013), Chapter VII: Anthropogenic and Natural Radiative Forcing, at 714, Table 8.7, available at http://www.climatechange2013.org/images/report/WG1AR5_Chapter08_FINAL.pdf. [ii] EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2013 (Apr. 2015), at ES-6, Table ES-2: Recent Trends in U.S. Greenhouse Gas Emissions and Sinks (MMT CO2 Eq.), available athttps://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2013. In this report, EPA uses a methane global warming potential (GWP) of 25 to reflect a 100-year timescale. However, the IPCC’s methane GWP of 86 for a 20-year timescale is a superior figure, both because it better reflects the time methane actually stays in the atmosphere before decaying into CO2—an average of 12 years—and because it reflects more recent science. [iii] Brownstein, Mark, EDF, Methane Emissions from Oil & Gas are on the Rise, Confirm Latest EPA Data (Apr. 15, 2015), http://blogs.edf.org/energyexchange/2015/04/15/methane-emissions-from-oil-gas-are-on-the-rise-confirm-latest-epa-data/. [iv] 80 Federal Register 56,593, 56,653 (Sept. 18, 2015). [v] ICF International, Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas Industries (March 2014), at 3-4—3-5, available at https://www.edf.org/sites/default/files/methane_cost_curve_report.pdf. [vi] The White House, Fact Sheet: Administration Takes Steps Forward on Climate Action Plan by Announcing Actions to Cut Methane Emissions (Jan. 14, 2015), available at https://www.whitehouse.gov/the-press-office/2015/01/14/fact-sheet-administration-takes-steps-forward-climate-action-plan-anno-1; The White House, Fact Sheet: U.S. Reports its 2025 Emissions Target to the UNFCCC (Mar. 31, 2015), available at https://www.whitehouse.gov/the-press-office/2015/03/31/fact-sheet-us-reports-its-2025-emissions-target-unfccc; Restrepo, Andres and Joanne Spalding, Sierra Club, Sierra Club Urges Immediate Action on Methane Pollution (May 26, 2015), http://www.sierraclub.org/planet/2015/05/sierra-club-urges-immediate-action-methane-pollution.
Image from WildEarth Guardians